Not enough science in fracking bans

Yesterday, the Federal government issued new recommendations for methods to estimate emissions from conventional gas and from coal seam gas production. So what did we learn?

The proposals seek to refine direct measurement of fugitive emissions from CSG wells that vent gas during a well work-over or well completion. In particular, they define the way in which direct measurement is conducted when fracking is used as a component of the extraction process. The new recommendations are based upon EPA guidelines introduced in the United States in 2011

Coal seam gas projects in Australia must undergo environmental assessment before approval. Environmental assessment requirements for CSG projects have been strengthened at both the State and Federal level. Particularly, where the project affects a water resource of national environmental significance, Federal regulation may require additional environmental evaluation.

Despite all of this, the effectiveness of environmental assessment for CSG projects remains questionable because of the absence of definitive scientific analysis regarding how CSG extraction and fracking affects groundwater tables, land stability and the density and volume of carbon emissions.

Both State and Federal legislation specifically incorporate the “precautionary principle”. This fundamental environmental principle says where there are threats of serious or irreversible environmental damage, we don’t have to wait for scientific certainty before introducing measures to prevent degradation of the environment.

This principle recognises that environmental problems generally arise in settings of risk and uncertainty. It accepts that environmental harms often do not manifest themselves until an extended period of time has elapsed.

The principle is, however, misleadingly simple. The critical question is how much “precaution” should be applied in a given circumstance. This has proven to be so variable that no single formulation exists to support a decision-making rule.

A literal reading would suggest that no CSG project should be approved in the absence of full scientific certainty regarding environmental impacts. Clearly, Australian regulators have not adopted this approach in the context of CSG projects to date.

Most environmental assessments of CSG projects are based onpotential environmental impacts. This type of predictive assessment is necessarily speculative and consequently, less rigorous. For example, a CSG project planned near the Great Artesian Basin will have a high likelihood of affecting groundwater aquifers that feed into the basin.

Depleting these reserves could significantly affect the sustainability of fragile ecological systems in these areas and thereby pose a threat of serious or irreversible damage.

But, because the complex nature of groundwater connectivity isnot fully understood, no definitive evaluation of the impact of CSG mining upon groundwater aquifers currently exists.

An environmental assessment of a proposed CSG project based upon the precautionary principle will therefore examine the possibility that mining in this area will deplete the aquifer and further, that depletion will cause serious environmental damage.

The precautionary principle will preclude a regulator from approving a CSG project on the grounds that there is no definitive scientific evidence to suggest that environmental damage will be caused.

It does not, however, provide any ultimate mandate. While the possibility of future environmental degradation must be taken into account, this assessment factor may be offset by other factors such as the immediacy of tangible economic benefits.

The real difficulty lies in the absence of any ongoing environmental assessment of approved CSG projects under either state or federal regulation. Once a CSG project is approved, the approval is enduring and the explorer is not required to undergo further environmental evaluation, even if new scientific data emerges.

And a CSG assessment can’t be suspended on the basis of inadequate environmental data.

How has the government responded to these difficulties? At the State level, it has introduced further layers of environmental review. In New South Wales, for example, when a CSG project affects areas mapped as “bio-physical strategic agricultural land” it has to undergo an additional layer of environmental review by an Independent Expert Scientific Committee on Coal Seam Gas and Large Coal Mining Development.

The process evaluates whether the proposed activities are likely to result in permanent or long-term loss of the land or to adversely affect agriculture.

This evaluation has three aspects to it, each of which is heavily dependent upon scientific data. The evaluation must consider whether:

CSG affects the land by reducing its agricultural productivity (because of surface area disturbance and subsidence, affects on soil profile, fertility and rooting depths, soil salinity, changes to soil pH, and impacts on highly productive groundwater)

the proposal would significantly affect “critical industry clusters” through surface area disturbance, subsidence, reduced access to agricultural resources, reduced access to support services and transport routes and loss of scenic and landscape values

The Independent Expert Scientific Committee is preparing bio-regional assessments for all areas where CSG development is planned. These assessments seek to evaluate the ecology, hydrology and geology of the areas and determine the potential risks of CSG mining to water resources.

But without completed research modelling on groundwater impacts, surface area disturbance, and soil fertility, how good can these assessments be? As Geoscience Australia has stated, the “current groundwater modelling is inadequate in terms of scale and detail to identify the impacts of multiple CSG developments on groundwater interactions”.

The position is not improved at the Federal level. The new water trigger in the Environmental Protection Biodiversity Conservation Act 1999 (Cth)(EPBC) means many CSG projects will have to be assessed federally.

The difficulty, however, is that the federal environmental assessment process is not measurably different to the state process. It continues to endorse the precautionary principle and is therefore likely to follow a similar “predictive” assessment regime.

The new Federal recommendations for the reporting of fugitive emissions from CSG projects represent a possible shift in perspective. This is especially the case with the proposed “well sampling” requirements which link the number of samples that need to be taken with the volume of well completions and also specify the number of years over which the emission sampling may be measured.

This “higher order” approach to scientific measurement will enhance the accuracy of outcome which, in turn, precludes the need to rely too heavily upon the precautionary principle.

David Llewellyn-Smith is Chief Strategist at the MB Fund and MB Super. David is the founding publisher and editor of MacroBusiness and was the founding publisher and global economy editor of The Diplomat, the Asia Pacific’s leading geo-politics and economics portal.

He is also a former gold trader and economic commentator at The Sydney Morning Herald, The Age, the ABC and Business Spectator. He is the co-author of The Great Crash of 2008 with Ross Garnaut and was the editor of the second Garnaut Climate Change Review.

Comments

“…..This “higher order” approach to scientific measurement will enhance the accuracy of outcome which, in turn, precludes the need to rely too heavily upon the precautionary principle…..”

The late Prof. Sir Paul Callaghan in NZ was scathing about NZ professing to be “pro science” and yet ignoring scientific evidence in favour of an ideological version of “the precautionary principle”. He was particularly referring to nuclear energy, but genetic engineering in food production was another thing he was in favour of.

We are fooling ourselves if we ignore that there is a sizeable political movement these days that is every bit as reactionary and anti-progressive and anti-science as the medieval papal establishment. And there is an altogether too mellifluous harmonisation between this ideology and bureaucratic self-interest.

Gas fracking has been through 30 years of development primarily through the efforts of George P. Mitchell who was one of the original Club of Rome participants. He is one of the early, sincere environmentalists who actually believed in solving problems facing humanity, with “progress”. I am quite confident that the scientific conclusions that have long since been reached about the safety of fracking, are the correct ones.

This technology has suddenly attracted the attention of the world’s reactionary enviro ideologues precisely because of its having reached commercial critical mass.

Oh well, people settle their own fate. Economic Darwin Awards, I call them.

Time will tell whether it was a better idea to frack and have low cost lower-carbon energy (US heartland and South) with the odd minor pollution incident, or to not frack, and have expensive energy, and avoid the potential minor contamination of 0.0000001% of your arable land (Australia).

No-one HAS to listen to us harsh realists, or emulate ignorant redneck hicks.

Future generations will look back on fracking the same way we look back on the introduction of the cane toad. They will say, how could we have been so obviously naive about the impact of pumping chemicals into our ground water.

As for the lack of science to back up the environmentalist claims, remember at one stage leading scientists thought the earth was flat.

Where, and how much of the time, has the chemicals pumped into the ground, ended up not just measurable “in the ground water” but measurable in water where it ends up being required to be safely consumed by humans?

If it is a problem, you stop it where it is a problem – just like there are no foundries in residential areas in first world countries any more. That doesn’t mean there isn’t any foundrying done anywhere anymore. We still need steel. We still need energy.

How does “mineral water” end up that way?

It is just a question which side in this argument, deserves the “flat earth” label. Ideologies are not inconsequential. When “science” is said to support a particular ideology, and both sides claim “science” in their support, which side’s “science” is the “flat earth” science? The “pro progress” science or the “anti progress” science?

If our ancestors had thought the way modern environmentalists do, we would never have even started using fossil fuels at all. Go on, argue that that would have been a good thing.

Its not about the chemicals pumped into the ground, as the CSG proponents would like to concentrate on. The volumes are low, and waste water received from the work can be treated. There arent insurmountable problems with that. There are insurmountable problems with the potential fracturing or puncturing of a groundwater table as a result of putting huge pressure into a coal seam. This can occur hundreds of metres away from the actual well. This is the event that can destroy a river or a landscape forever. You cant stop an uncontrolled leak of methane or mineral rich groundwater coming up from 800m under the ground surface once it has found its way out! The CSG companies have no way of guarding against this event, and no way of remediating it. Its pure guesswork and hope that they don’t have an unlucky well. It should be banned completely in arable land for this reason.

‘If our ancestors had thought the way modern environmentalists do, we would never have even started using fossil fuels at all. Go on, argue that that would have been a good thing.’

That’s not what I’m saying at all. I am all for progress, but I don’t want the mistakes of the past to be repeated. Potentially poisoning your water source and arable land so a few privately owned companies can make a profit is complete madness. Hardly what I’d call progress.

All human progress has involved some degree of risk. We have not banned fossil fuels because spillages have occurred, and we should not ban fracking just because of a few much less serious incidents that have not even happened yet, and are inconsequential on the scale of “total land available for whatever uses”. The “spoiling a few hundred square metres of arable land” excuse is one of the feeblest imaginable. The COST of the damage is nothing compared to the benefit of the energy availability, just as with oil spills and dare I say it, coal mining deaths, although I am reluctant to stand by this last (it is just that we have never shut down coal mining, so there must be a democratic acceptance of the reality). I would have said “more fracking and less coal mining” would be exactly the kind of advance I am advocating.

Phil, the problem is the LACK of Scientific research. The industry relies on this lack & Govt. takes the Industries word for the safety of their operations .
With people of the stature of Eddie Obeid & Ian MacDonald running the process in NSW & the recent 4Corners exposure of the QLD governments complete lack of process for 2 of the biggest CSG gas projects in that state it is not reactionary but essential common sense on the part of exposed communities to reject this industry until it is proven safe. Our water air &soil health as well as the health of humans ,animals & flora is paramount.
The Coal & Gas industries are Rogue industries whose use by date is fast approaching . The future ,if there is to be one, is with renewable ,clean & safe energy .

Therefore, “the science” HAS to reach a certain conclusion, or it won’t BE science according to the people who hold this belief. As I was saying, about ideology not being inconsequential…..

Go on, argue that the world without any oil and gas industries at all at any time, would have been a better place. There were no “oil and gas industries” in the former communist countries, but they still managed to wreck their environments worse than any “capitalist” country.

I’d trust scientists to test it and see if there is any harmful transfer of chemicals into ground water. There are plenty of places in Australia and the world where mining is done so remotely from civilisation that no-one bothers about local enviro impacts. At worst, it is simply a matter of working out “where” it should be done, and “how close” it should be allowed to be done to urban areas.

THIS very interesting analysis uses “accessibility to a city” to suggest that 95% of the world’s population lives on the 10% of the world’s land from which a city is accessible. Only 5% lack accessibility to a city.

Kingaroy in Qld about 4years ago, Gas mining Co. Cougar given leases over compulsary Aquired land including Sir Joh’s home property. BTEX chemicals reported in adjoining farms water bores . The government suspended operations for 6months & did an investigation. Government cancelled Cougar’s licence &banned the process being used ,Underground Coal Gasification.
The Government won the ensuing court case. UCG is still legal in NSW.

George P. Mitchell also built The Woodlands, environmentally friendly, luxury and affordable housing, with major employers positioned within the master planned community and made billions from it. An now the worlds biggest company purchased 500 acres next door 15 minutes from the Houston international airport and building their world wide headquarters and you can still buy a nice home for under 200k, with a average income of over $130k. I would take his opinion over others anyday.

I do see this as highly relevant. The same unreason possesses people’s minds, on urban planning, as it does on resources and the environment.

People are so obsessed with the “negative externalities” and “the precautionary principle” that they cannot see that human history has all been a long series of trade-offs between positive externalities and negative ones, and the “net” of positives over negatives has steadily increased. This is both because the positive ones have increased and the negative ones have decreased, at each phase of technological advancement.

I would credit George P. Mitchell with being a wise man on all these counts. The net benefit to humanity of urban development of the kind that “the Woodlands” represents, and the net benefit to humanity of energy resource extraction of the kind that “fracking” represents, will both be substantial, an advance over the status quo, and superior to other ideologically-rooted alternatives.

The idea that mandated “renewable, clean and safe energy” will result in an increase in “net benefit” over the status quo, is just as stupid as the idea that mandated “compact city urban planning” will result in an increase in “net benefit” over the status quo.

Note the word “mandated” in that sentence. Humanity will end up with the best possible of all worlds anyway if we know how to USE the free market along with fiscal “nudges” in the right direction and sensible protections like disallowing foundries from operating in residential areas.

The chemical used for fracking is a ‘trade secret’, therefore it is impossible for outside scientist to evaluate whether it is safe to use. By the time we discover it’s not safe, it’ll be too late.

For a new technology like this, the sensible approach will be :

1) Don’t do it near where a lot of people live
2) Don’t do it near major waterway and water aquifers.

That would be the sensible approach, and you will only allow CSG and Fracking near agricultural land when the industry can convincingly prove it’s safe.

State Government agencies can often lose perspective of the ‘big picture’. One glaring example allowing CSG operation INSIDE the water catchment area of the Warragambaa dam, which supplies most of Sydney’s water supply. Even the company who obtained the approval realize they’ll be crazy to drill there, yet the government still grant them a license to drill anyway?

You’ll see that most of them are quite common, generally used in low concentrations, in low volumes, where losses are relatively small compared to the surrounding water (if there is any surrounding water at all), if losses occur at all. And most are only used in setting up the well.

The majority of the fraccing stream is always, and will remain, sand (proppant) and water (carrier fluid), to the tune of typically > 98%.

As you can see, there are few “trade secrets” in fraccing chemistry, so, with respect, I’m not really sure what you are talking about. It’s not really all that complicated.

Regulate, for sure – but blankets rules ignore that fact that site’s should be evaluated on a case-by-case basis (eg. some seams are not even in the water table…so how can they pollute the water table (ignoring the fact that concentrations are normally so low that they would quickly be diluted or immobilised even if they did have small fraction of the fluid actually leak)).

The tendency of flowing water to end up pure after all the places it has been and what has got into it, is one of the wonders of nature.

It would not surprise me at all if some brands of mineral water have sufficient traces of some elements that it would drive enviro activists nuts if it was groundwater near some industry or mining or fracking or evil capitalist activity.

Neither of your (PB & Blurbwatcher) comments do anything to answer the question:

Given that
a) we start fracking under Sydney’s water supply; and
b) Something goes badly wrong and we end up with contaminated water
c) What do you both suggest Sydneysiders do next?

I’m no extremist tree hugger by any means, but I do understand the concept of risk. There’s a HUGE difference between:
1 Contaminating land in the middle of nowhere;
2 Contaminating an area of agricultural land ([email protected]@er the farmers) ; and
3 Contaminating a major city’s water supply.

Would you be willing to bet your life on leases rushed through by those involved to the degree that the Obeids & McDonald’s are alleged to be? The point is, there’s no comeback if you opt for number 3 above. Do we think we know it all? How many Windscale fires, Three Mile Islands, Bophals & Fukushimas do we need to learn the obvious wisdom of not playing with fire in areas of high population density? Good Grief.

Bhopal..
And while I’m at it, I should explain that the definition of risk has to take into account that sometimes you don’t know what you don’t know.

When the Comet airliner was first introduced, everything went just fine for a while until a series of unexplained mid-flight crashes. It was only after extended investigation that engineers discovered they had no idea about some of the causes or even symptoms of metal fatigue.

Nuclear reactor fires were far more likely to occur than first thought because certain metallic elements were (unknown to them) being formed through nuclear chemistry inside the reactor. Pass hot steam (the coolant) over finely divided Nickel and it separates into (hot) Hydrogen & Oxygen. Oh Dear…

Nothing I said could be interpreted as advocacy of this. There is 99.6% of Australian landmass that is not urbanised, it might be an idea to start there with things like mines and fossil fuel drilling.

I am agaisnt CSG in catchments, you can cop a fine of 40k if you go walking in one but you are allowed to frack, cant figure it out.

The other aspect that the SCA and Sydney Water are two separate organisations, and Sydney Water is a mixture of private companies one of which is owned by the Obeids and has or did have Sindonis who was the treasurer for the NSW LNP as a director, the other group is Veolia who also run the desalination plant.
A previous head of the SCA told audiences at a CSG rally that while he was head of the SCA there would be no fracking. He was removed within a month to a new position within Sydney Water

Even putting aside the damage that fracking does to the land and watertable, CSG should be rejected because of its greenhouse contributions.

1. If CSG projects had to pay the carbon tax on actual fugitive methane emissions, rather than guestimates, then that would probably sink a lot of projects.

2. There was a time when the idea of gas as a transition phase bridging the way to renewables seemed to make sense. Now it is clear that gas is a great distraction. The capital that has been spent (and is planned to spent) on CSG, LNG, gas-fired electricity generation, pipelines etc could buy a helluva lot of renewable energy. Worse, it is becoming increasingly clear that we aren’t going to be able to afford burn more than a fraction of our fossil fuel reserves, and so all these investments will become stranded assets.

And I just saw a delightful calculation by Lord Monckton, not online yet as far as I know, of the cost-effectiveness of abating CO2 by way of the carbon tax scheme Australia has enacted. It is approximately 50 times as costly to mitigate CO2 by this means, as it is to “adapt” to the consequences of the CO2 mitigated in the event of non-mitigation. By the IPCC and Stern Report figures.

We discussed this on another thread recently. This is nonsense. It is simply not remotely possible at current levels of technology. The time will come, but it is not here yet.

There are taxes on one and subsidies on the other. This is the reason “why” one is “cheaper” than the other. Otherwise there is no point even having the taxes or the subsidies, and I can assure you that without them, there would be only the barest fraction of the commercial “renewables” investment that there has been.

He is a figurehead of something, just as Al Gore is. You know, the guy who never debated anyone, because the time for it was over before anyone even had one. Read Monckton’s stuff. Watch his videos. He does not have to be a scientist, to spot the gaping flaws and demonstrate mathematically an absurdity like what I just said. One side in this argument is committing irrationality after irrationality, and the other is pointing it out.

Monckton, a mathematician, is incidentally an IPCC expert reviewer and has found mistakes in complex formulas that the IPCC has adjusted in response. Most of the reviewers are not scientists. Economists review the chapters on economics. Mathematicians check formulas and calculations. The economist Stern says one thing, and no-one criticises him. Monckton (not just him, either, BTW) points out how Stern did his maths, and he is a “naughty boy”, apparently.

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